Privacy Policy June 2019

Effective Date: June 6, 2019

We take the privacy of our Websites’ users very seriously. We ask that you read this Privacy Policy carefully as it contains important information about how we will process your Personal Data (defined below).

  1. Definitions

In this Policy, the following words have the following meanings:

  • “Account” means an account that you set up and which records data such as your email address, personal information etc. and through which you are able to post Content and purchase goods. Depending on the Website, a User may or may not be required to register an Account. An Account can never be transferred to a third party.
  • “Content” means any text, images, video, audio or other multimedia content, software or other information or material submitted to or on the Website (defined below), together with any and all correspondence between Users and/or us.
  • “Contact Form” means the form available at which may be used to contact Brand Access, LLC to obtain information or for any other reason.
  • “Login Details” means your username and password which may or may not be required to use of the Website.
  • “Personal Data” means any data which relates to a living individual who can be identified from such data.
  • “Privacy Policy” means this privacy policy.
  • “Bungie” means Bungie, Inc., an Bellevue, WA based corporation.
  • “We, us or our” means Brand Access, LLC, a Limited Liability Company established in the State of CA, United States, registered under Federal Tax ID number 81-2601260, Dutch VAT number NL824361222B01, Spanish VAT number N4008909F, France VAT number FR 11838506541, and whose office is at 900 High Street, Palo Alto, CA 94301, USA.
  • “Website” means:
  • You” or the “User” means any individual who accesses and uses the Website. Users may be required to register to use part of the Website by setting up an Account which will permit them to upload, download, edit and/or exchange Content. 
    1. Identity of Data Controller

    We are the data controller responsible for processing the Personal Data acquired through our operation of the Website. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

    1. Data Processing and Collection

    To protect your Personal Data, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

    Through our operation of the Website, we are likely to collect Personal Data relating to Users of the Website which is processed for a number of different purposes as set out in this Privacy Policy.

    In particular, we may collect Personal Data:

    • when you visit any of the Websites;
    • when you use features and/or services offered on any of the Websites;
    • if you are required to register, when you create and update your Account; and
    • when you contact Brand Access LLC, or other Users of the Website. 


    However this data is collected, we are committed to only processing this data strictly in accordance with our obligations under applicable legal requirements (as amended from time to time) and applicable laws. We will also endeavor to provide you with details as to our data processing purposes, to identify the individuals responsible for such processing and to provide you details of your statutory rights to access, amend and delete your Personal Data as appropriate.

    Where necessary and/or required under applicable law, we will seek to obtain your consent prior to the processing of Personal Data and/or allow you to object to such processing.

    We will only collect Personal Data to the extent necessary for us to operate and provide services through the Website and as set forth below in the Section entitled “Purposes of Data Processing”.

    Personal Data that we may collect and process includes:

    • contact Information such as name, email address, residential address and phone number;
    • unique identifiers such as your Login Details;
    • data relating to previous transaction history such as account and order details;
    • location information such as your actual or approximate location through your IP address;
    • details given in respect of our contests, lotteries and any promotions hosted via the Website;
    • billing information such as credit card number and billing address. Please note that credit card details are deleted following the conclusion of each transaction, i.e. when money is received in full, save when retention is permitted in accordance with applicable laws or in the event of a dispute;
    • details of processed invoices including any discounts granted and any unpaid bills; and
    • geographical details.
    1. Purposes of Data Processing

    We may use the information we collect about you to:

    • ensure the Website functions correctly and allow us to improve our services and features;
    • administer User’s Accounts (if applicable);
    • respond to User’s service requests, questions and concerns;
    • comply with any subject access requests we may receive from Users to access their data for the sake of rectification and/or to oppose the processing of such data;
    • in the event of a dispute or legal proceedings;
    • conduct research and analysis to improve the operation of the Website and the quality of services;
    • administer promotions and sweepstakes you may enter; and
    • send promotional materials including but not limited to:
      • updates and newsletters about our partners or related special offers;
      • requested information about products or services;
      • a one-time email or e-card to your friends, at your request, when you provide their email addresses; or
      • upcoming promotions and sweepstakes and the results of such events (as applicable).

    We also may collect geographical data about you in order to improve our services and User interactivity with the Website.

    We may use your Personal Data as necessary to comply with our legal or regulatory requirements. Your Personal Data will not be processed in any manner that is incompatible with the purposes listed in this section.

    In all circumstances and for all personal data collected, we undertake that we will only process your Personal Data in accordance with legal requirements (as amended from time to time).

    1. Consent

    If you are required to register an Account with the Website, it will be necessary for you to provide certain details and Personal Data.

    By voluntarily providing such Personal Data and through your continued browsing or use of the Website, you consent to that data being collected and processed by us for the purposes set out in this Privacy Policy.

    We will not send you marketing or promotional materials unless we have received your express confirmation that you would like to receive such information. 

    1. Access to Personal Data

    Only certain individuals and entities will have access to your Personal Data as listed below:

    • our representatives and affiliates;
    • our employees who are involved in managing the client relationship and ensuring the functionality of our Website services, for example processing orders and arranging deliveries;
    • business partners who have contracted with us and agreed to similar data protection obligations;
    • our commercial, financial and advertising partners;
    • any organizations or individuals who we may engage in the event of a dispute or legal proceedings;
    • administrative, public or judicial authorities who are permitted by lawful requests to receive such data including to meet national security or law enforcement requirements;
    • reputable third parties in whose products or services Brand Access, LLC thinks you may have an interest (with your consent);
    • in connection with a corporate change including a merger, acquisition or sale of assets to any other third party, (with your consent). 

    Given that we are selling Bungie branded goods and products via the Website we will share information we collect about Users and their use of the Website, including Personal Data, with Bungie and Bungie may process, store, and use such information, including Personal Data, in connection with the operation of online and ecommerce websites and services. In addition, you understand and agree Bungie will have access to and will use such information, including Personal Data, in the event that we are no longer involved in the operation of the Website. 

    Your Personal Data is not transferred, sold or accessible by any persons other than those listed above and we have liability in cases of onward transfers to third parties.

    Our Website may offer different methods for updating your Personal Data. To review and update your Personal Data on stores, please log into your Account on each Website where you have registered.

    To update your billing or shipping information for purchases, please follow the customer service instructions in your order confirmation email.

    If you wish to cancel or delete your Account or request that we no longer use your information to provide you services contact us by clicking here. We will respond to your request within 30 days.

    1. Data Retention

    We shall not keep your Personal Data for longer than is necessary to fulfil our data processing purposes.

    We will not record or store credit card details or details of any other form of payment once the transaction has been carried out, save in the event of dispute. We will never store your security code.

    1. Data Connection and Cookies

    We collect information about your connection to the Website, for example what page you are viewing and at what time.

    We also use cookies whenever you visit any Website. The details of which cookies we use and how we use them is set out in our Cookies Policy which is available here.

    Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies or not.


    • _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
    • _shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
    • _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer
    • cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
    • _secure_session_id, unique token, sessional
    • storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.


    1. Social Networks

    Through your use of the Website, it may be possible to share Content directly onto third party social media websites such as Facebook or Twitter. When you access these external websites, please be aware that their privacy practices may differ from our own and any Personal Data you submit through these websites will be governed by their respective privacy policies. We therefore encourage you to carefully read the privacy policy of any external website you visit and/or post data on, notwithstanding that you accessed the external website through our Website.

    1. Security and Confidentiality

    We are committed to taking appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction or damage to Personal Data.

    These measures include equipment and information security, access security and training of our employees who are required to process Personal Data about this Privacy Policy and the appropriate processing of Personal Data.

    1. Transfer outside the EU

    The Website is hosted in the United States and we provide the Website from the United States. Information about European Union and Switzerland residents may be sent to the U.S., where it is processed in accordance with this Privacy Policy and our Cookie Policy, the E.U.-US Privacy Shield Framework (in the case of EU residents) and the Swiss-U.S. Privacy Shield Framework (in the case of Switzerland residents). Brand Access, LLC complies with the E.U.-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Please note that the Privacy Shield principles do not necessarily apply to the collection, use, and retention of Personal Data from other countries. Brand Access, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

    In compliance with the Privacy Shield Principles, Brand Access LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brand Access at 

    Brand Access LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPA’s) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred to the EU and Switzerland.

    Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration may be available before a Privacy Shield panel.

    1. Security

    To protect your Personal Data, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

    If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

    1. Tracking Technologies

    We and our third party partners may automatically collect information as you browse our Website such as the domain name, Internet Service Provider, browser type and version, mobile device ID, operating system and device type, average time spent on our Website, pages viewed, information accessed, the Internet Protocol (IP) address you use to connect to the Internet and related geographical information about your computer or mobile device. Such information is sometimes referred to as web analytics and/or clickstream data.

    We and our third party partners use cookies and other technologies such as web beacons to keep track of your visits, preferences and profile information. This information is used to make our Website easier to use, improve our advertising, and to provide you with a more personal and convenient experience. For example, we may use this information to store some of your preferences or to provide you with tailored advertisements related to your specific interests. Additionally, should you choose to enroll, we and our third party partners may use this information to allow you to participate in one of our fan rewards programs. To learn more about the use of cookies in online advertising, including how to manage or delete them click here.

    We and some of our third party partners use Flash cookies to store some of your preferences or Personal Data. For more information on Flash cookies and how to manage privacy and storage settings click here. To view our full Cookie Policy please click here.

    In some of our email messages, we use “click-through URLs” or pixel tags to determine whether the email has been opened and to measure the effectiveness of our customer communications. This data may also be used to gauge your interest in particular topics, so we can deliver a more relevant, personal and convenient user-experience

    1. Your California Privacy Rights

    If you are a California resident, California Civil Code Section 1798.83 provides you the right to receive (a) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your Personal Data for that third party’s direct marketing purposes; and (b) a description of the categories of Personal Data disclosed. To obtain such information free of charge, please write to us at the address below, or submit your request here. We will respond to these requests within thirty (30) days. Requests that come to us by other means may result in a delayed response.

    1. Responding to Do Not Track Signals

    Our Website does not have the capability to respond to “Do Not Track” signals received from various web browsers.

    1. Promotions and Sweepstakes

    From time-to-time, we may provide you the opportunity to participate in promotions or sweepstakes (each, a “Promotion”) on the Website. Each Promotion may have additional terms and/or rules which will be posted or otherwise made available to you and, for purposes of each Promotion. If you participate in a Promotion, as part of the registration process, we may request certain additional Personal Data from you. Participation in any Promotion is completely voluntary and when you choose to participate in such a Promotion, you expressly consent to the use of any Personal Data you submit in accordance with this Privacy Policy and any additional terms applicable to such Promotion. Requested additional information may include contact information (such as name, e-mail address, telephone number and/or shipping address), and demographic information (such as zip code). We use this information to administer the Promotion, notify a winner and distribute any prizes.

    We may use a third party service provider to conduct these Promotions, and we may share your Personal Data with such third party service providers solely for the purpose of conducting these Promotions.

    1. Links to Other Sites

    The Website includes links to other sites whose privacy practices may differ from those of Brand Access, LLC. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any site you visit.

    1. Our Policy Towards Children

    Children – We do not attempt to collect any Personal Data from those under the age of 13. If you feel that we have unknowingly collected information from someone under the age of 13, please contact us and this information will be removed as soon as possible.

    For more information on how to protect your children online:

    Visit for social networking safety tips for parents and youth.

    1. General

    Any information that is collected via our services is covered by the Privacy Policy in effect at the time such information is collected. We may modify or amend this Policy at any time.

    By using the Website, you agree to the terms of this Privacy Policy. In the event of a material change to the Privacy Policy or to the way in which we collect, use and/or share your Personal Data, we will update Users by emails or post a notice on the applicable Website, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective.

    Your continued use of this Website indicates your acceptance of these terms and policies.

    1. Questions About This Privacy Policy

    If you have questions or concerns regarding this Privacy Policy, please contact us. You can contact us about this Privacy Policy at our address provided below.

    Brand Access, LLC

    900 High Street,

    Palo Alto, CA 94301